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Ottawa, 11 October 2012

Our Reference: 8740-T66-201209099


Mr. Hal Reirson
Senior Regulatory Advisor
Telecom Policy & Regulatory Affairs
TELUS Communications Company
30-10020-100 Street NW
Edmonton, Alberta T5J 0N5

RE: Tariff Notice # 438 / 644 / 4357

Dear Mr. Reirson:

The Commission is in receipt of the response to interrogatories regarding Tariff Notices (TN) 438 / 644 / 4357 from TELUS Communications Company (TELUS). These applications relate to changes to Carrier Access Tariffs for which TELUS is proposing to add a 2.5 Gbps interconnecting carrier to interconnecting carrier (IC-to-IC) cross-interconnection link.

Commission staff has reviewed all the documents submitted and in order to assist the Commission in disposing of these applications, TELUS is requested to provide responses to the additional interrogatories in Attachment 1 which are to be filed with the Commission by 26 October 2012. These responses are to be received, and not merely sent, by this date.

Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date. Copies of the documents should also be sent to and

Yours sincerely,

‘Original signed by

Yvan Davidson
Director, Competitor Services and Costing
Telecommunications Directorate

Attach. (1)

Telus 2.5 Gbps IC to IC Cross-interconnection Link
TNs 438 / 644 /4357


1. Refer to the response to Interrogatory TELUS(CRTC)14Aug12-5 where the company stated that the cost of the transmission equipment provided were calculated by taking the manufacturer net price for each card, multiplying it by 2 to arrive at the total net equipment cost. Further, refer to Note 6 of the proposed Tariff pages where the company stated that the provision of an IC-to-IC Cross-Interconnecting Link requires that each IC pre-order a Central office Link.

Explain based on the above, whether each interconnecting carrier would have to pay the 2.5 Gbps IC-to-IC link service rate. If so, explain why.

2. Explain if a 1 Gbps IC-to-IC link service could be offered (or a link service speed less than 2.5 Gbps). If not, explain why not. If so, provide a cost study for a 1 Gbps IC-to-IC link service (or a link service speed less than 2.5 Gbps) and the proposed rate. The response should provide cost study information in the same level and format of cost detail as requested by the Commission in this proceeding (e.g. cost detail as provided in response to Interrogatory TELUS(CRTC)14Aug12) .


3. With reference to the company`s response to Interrogatory TELUS(CRTC)14Aug12-3 and to Table 5 of the company’s revised 5-year economic study,

  1. Refer to part b) of the response to Interrogatory TELUS(CRTC)14Aug12-3 where the company identified a number of billing activities which are recurring in nature. Identify all the activities that are included in the Expenses causal to the service -Billing related and explain whether these activities are recurring or non-recurring in nature. For the expenses that are recurring in nature, explain why they were included in the expenses causal to the service. For the expenses that are non-recurring in nature, identify each activity and explain why they are deemed to be causal to the service, further provide a breakdown of the total billing costs by major non-recurring billing activity.
  2. For each of the following expenses:

    Expense causal to the service – Billing related,
    Expense causal to demand – Maintenance,
    Expense causal to demand – Advertising and sales Management,

    Show how the unit costs taken from TELUS 2007 Activity Based Costing (ABC) study are used to develop each expense estimate. The response should identify the 2007 ABC unit cost values used and the methods and assumptions used to develop the cash flows.

Capital Costs

4. With reference to the company`s response to Interrogatory TELUS(CRTC)14Aug12-5, Attachment 1, where the company included a cost for its Engineering Furnishing and Installation (EF&I), describe the methodology used to develop these unit costs or factors along with supporting assumptions. The response should include the unit costs or factors that are used to calculate the EF&I cost with the major activity.

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